Memorandum submitted by the Trades Union
Congress (SS 06)
1. The TUC is the voice of Britain at work,
representing 7 million workers in every walk of life and with
a long-standing interest in social security. During a period of
change at the Department of Work and Pensions, we recognise that
the present role and future responsibilities of the Social Security
Advisory Committee (SSAC) is an appropriate topic for consideration,
and we are grateful for this opportunity to submit comments to
the Committee's inquiry.
2. The TUC and unions have a high regard
for the SSAC, and especially for its scrutiny of proposed regulations.
3. The advantages of an independent expert
body in this area have been illustrated by the Committee's successful
assumption of its new remit to scrutinise DWP information products.
SSAC's independence and expertise promote public confidence in
4. Unions have a vital interest in the development
of social security policy, and value their representation on the
5. The TUC would welcome the introduction
of local advisory/consultative bodies.
6. The TUC would support extending SSAC's
remit to include tax credits, National Insurance and Child Benefit.
7. In preparing its response to this inquiry,
the TUC carried out its own consultation exercise, which showed
that unions hold it in "high esteem," see it as "useful",
"important" and "recognise, value and continue
to support the Committee's work."
8. Unions have particularly high regard
for SSAC's scrutiny of proposed regulations. Given the continuing
significance of welfare to work in the Government's overall scheme
of things, unions are convinced that the scrutiny of regulations
(and social security developments more generally) is an essential
9. The SSAC's new remit of scrutinising
the DWP's information strategy and individual Departmental products
is an important development. When the inherited SERPS affair blew
up the Secretary of State needed an independent body that could
be trusted with this task, to provide an extra reassurance that
similar problems would not recur: if the SSAC had not existed
it would have been necessary to invent it.
SSAC AND WELFARE-TO-WORK
10. The TUC strongly supports the Government's
emphasis on welfare-to-work, and we believe that the work of the
SSAC encourages vital public support for this policy. The success
of welfare-to-work depends (among other things) on changing widely-held
attitudes and assumptions, and rigorous and independent scrutiny
of the policy can bolster public confidenceessential if
these changes are to be achieved and maintained.
11. The Government's willingness to submit
its plans to independent scrutiny is an indicator of its self-confidence,
and the fact that the Committee can and does recommend improvements
is the guarantee that this scrutiny is genuinely independent.
SSAC AND GOOD
12. The SSAC also contributes to good government.
The public consultations when proposals are formally referred
to it provide a forum for informed discussion of novel and potentially
contentious proposals. The Committee often receives detailed and
well-informed comments from those who will implement or be affected
by proposals. The SSAC's reports do not necessarily reflect all
the comments it received in the course of a consultation, but
they do take account of them, and the Committee is often able
to draw Ministers' attention to practical difficulties.
13. The TUC values the statutory provision
for one member to be appointed after consultation with unions.
Unions have a well-established interest in the benefits system.
Beveridge called the TUC "the Godfathers of the Beveridge
report" and noted that, "with the exception of one point
there is little difference between my proposals and the proposals
of the TUC." (The History of the TUC, 1968, p 126.)
14. The TUC was calling for a welfare-to-work
focus in social security policy long before it became a political
rallying-cry, and the occupational pensions and other benefits
our affiliated unions negotiate will be important features of
any future system. We continue actively to contribute to national
debates about social security, and produce extensive briefing
materials for union members. The statutory provision for a member
of the SSAC to be appointed after consultation with the TUC guarantees
an employee voice in discussions about an area of policy vital
to their interests.
A LOCAL VOICE
15. The TUC would encourage the Select Committee
to consider the case for establishing local advisory and consultative
committees. We are concerned that the polarisation between officials
who draft legislation and those who are affected by it is possibly
greater in social security than any other policy area. Bridging
this gap is difficult: social security legislation is complex,
but recipients are extremely disadvantaged and less able than
other groups to ensure their voice is heard when changes that
vitally affect their interests are being considered.
16. The SSAC has a good record of considering
the impact on the poorest claimants when scrutinising proposed
regulations. This is to be commended, but a single London-based
Committee will inevitably be seen as distant by claimants.
17. Before 1980, the National Insurance
Advisory Committee played a similar role to the SSAC. The TUC
does not support a return to the pre-1980 arrangements, but we
do believe that one advantage of this system was to be found in
NIAC's more than 200 local advisory committees. A more modern
form of local body one could envisage Community Benefit
Forums, analogous to the new Patients' Forums in the NHSmight
help to build new links between those affected by social security
policies on the one hand, and those designing and implementing
them on the other. The reports of such forums could also provide
a valuable resource for the SSAC and other bodies commenting on
proposed policies and regulations.
18. Unions, as indicated above, value the
SSAC. We also believe, however, that if it is to remain relevant
the Committee's remit must be extended, and that otherwise there
is a risk that SSAC will become less relevant to important policy
debates. We accept that addressing this issue will require the
allocation of extra resources.
19. We believe that SSAC's remit should
be extended to cover National Insurance, Child Benefit and tax
National Insurance Contributions
are paid by millions of working people, and eligibility to many
benefits depends upon ones NIC record.
Similarly, Child Benefit is an essential
plank of the Government's policy to eliminate child poverty.
From April 2003 the new tax credits
will form an element of the incomes of millions of working people.
Tax credits are intended to deliver the Government's aims of making
work pay, tackling poverty and social exclusion.
20. Even though tax credits, National Insurance
and Child Benefit have been transferred from DWP to IR they are
central features of our social security system. SSAC has an informal
agreement that enables it to comment on IR proposals, but we worry
about a situation in which the SSAC's statutory authority does
not extend to those elements of provision that are most vital
to the Government's welfare reform agenda.
1 The TUC wanted the industrial injuries
to be entirely separate from National Insurance.